RECENT OFAC CIVIL COMPLAINT SETTLEMENTS FOR SANCTIONS VIOLATIONS
December 24, 2018
Société Générale, S.A. – $54 Million
On November 19, 2018, OFAC announced a nearly $54 million global settlement between the French bank Société Générale, S.A. (SG) and the Board of Governors of the Federal Reserve System, the U.S. Department of Justice, the New York County District Attorney’s Office, the U.S. Attorney for the Southern District of New York, and the New York State Department of Financial Services.
SG voluntarily disclosed violative transactions totaling around $5.5 billion over the course of an investigation that involved multiple regulators and ran from 2012 to 2017. The investigation scope covered transactions in retail, corporate, correspondent, and investment divisions from January 1, 2003 to December 31, 2013, as well as policies and procedures during that time. According to the settlement, “SG’s review revealed that the bank processed certain transactions in a non-transparent manner that removed, omitted, obscured, or otherwise failed to include references to OFAC-sanctioned parties.” At one point in the early 2000s, some individuals in the bank had circulated guidance how to process transactions without alerting U.S. authorities. Later, the bank improved its compliance programs, but some business units continued to improperly process transactions or delete required documentary information.
Cobham Holdings, Inc. – $87,000
On November 27, OFAC announced an $87,507 civil settlement with Cobham Holdings, Inc. of Arlington, Virginia on behalf of its former subsidiary Aeroflex/Metelics, Inc. Aeroflex/Metelics was involved in indirectly exporting components of a commercial air traffic control radar to a specially designated national in violation of the Ukraine Related Sanctions Regulations, 31 C.F.R. Part 589. Cobham self-disclosed the violations and OFAC concluded they constituted a non-egregious case.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Alexander Matthews (amatthews@eckertseamans.com or 202-659-6633).
Share This Post
Authors
